COLJI-Crim. 6-4:08

The elements of the crime of child abuse (knowingly allowing

exposure to precursor chemicals) are:

1. That the defendant,

2. in the State of Colorado, at or about the date and place charged,

3. knowingly,

4. was a parent or lawful guardian or person having the care or

custody of a child, and

5. allowed the child to be present or reside at a premises or to be

in a vehicle where the parent, guardian, or person having care

or custody of the child knew, or reasonably should have

known, that another person possessed ephedrine,

pseudoephedrine, or phenylpropanolamine, or their salts,

isomers, or salts of isomers, with the intent to use the product

as an immediate precursor in the manufacture of a controlled

substance.

[6. and that the defendant’s conduct was not legally authorized by

the affirmative defense[s] in Instruction[s] ___.]

After considering all the evidence, if you decide the prosecution has

proven each of the elements beyond a reasonable doubt, you should find

the defendant guilty of child abuse (knowingly allowing exposure to

precursor chemicals).

After considering all the evidence, if you decide the prosecution has

failed to prove any one or more of the elements beyond a reasonable doubt,

you should find the defendant not guilty of child abuse (knowingly

allowing exposure to precursor chemicals).